Since early 2025, the European Commission has been conducting a deep revision of two directives that had mobilised entire teams in IT and finance departments across mid-sized enterprises: the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability Due Diligence Directive). The result is the Omnibus package. It is now in force: the first part, known as “stop-the-clock”, entered into application in April 2025; the substantive directive (Omnibus I) was published in the EU Official Journal in February 2026.
For a CIO or CFO at a mid-sized company, the question is straightforward: what does this actually change for IT investments already made, or those still on the fence? This guide answers without legal jargon.
What Is the EU Omnibus Directive and Why Does It Change the ESG ERP Landscape?
The February 2025 Proposal and the “Stop-the-Clock”
On 26 February 2025, the European Commission published a legislative package aimed at reducing sustainability reporting obligations for European businesses. The package had two components.
The first component, processed under an accelerated procedure, is Directive 2025/794 known as “stop-the-clock”: adopted on 16 April 2025, it immediately suspends obligations for the second-wave CSRD companies. In practice, companies with more than 250 employees that were not yet subject to NFRD saw their first reporting obligation pushed back by two years — it now applies to financial years beginning on or after 1 January 2027 (rather than 2025 as originally planned). The CSDDD, meanwhile, has its transposition deadline extended to 26 July 2027 and its first wave of application to 26 July 2028.
The second component, more substantive, is Omnibus I Directive, published in the EU Official Journal on 26 February 2026 after an inter-institutional agreement in December 2025. This is the text that durably reshapes the scope of both directives.
New CSRD Scope: Which Mid-Sized Companies Exit — and Which Remain
Omnibus I significantly raises the CSRD application threshold. According to the Commission’s proposal (COM(2025)80 final), only companies simultaneously meeting both criteria below would be subject to mandatory reporting:
- More than 1,000 employees on average over the financial year
- Net turnover exceeding €50M or total balance sheet exceeding €25M
The volumetric impact is massive. The Commission estimated a reduction of approximately 80% in the number of companies affected, falling from around 50,000 to roughly 5,000 entities across the European Union. For mid-sized European companies with 250 to 1,000 employees — which represented the bulk of the “second wave” — exit from mandatory scope is now confirmed.
Companies remaining within mandatory scope are large listed and unlisted companies exceeding the new threshold, as well as European subsidiaries of non-EU groups generating more than €150M in turnover on EU territory.
Simplified CSDDD: What Changes for Supply Chain Due Diligence
The CSDDD, the directive on corporate sustainability due diligence, is also being reformed substantially. The first-wave application threshold rises to more than 5,000 employees (versus 1,000 in the original text), with a revised upward turnover threshold. This evolution directly impacts ERP supplier management modules: obligations to map and monitor the supply chain now apply only to the largest organisations.
ERP ESG/CSRD Modules: What Changes, What Stays
Carbon Data Collection: Still Valuable, Even Outside Mandatory Scope
Exiting CSRD scope does not mean carbon data loses its value in your information system. Large companies that remain subject to CSRD must still report their scope 3 emissions — the indirect emissions tied to their suppliers and subcontractors. If your key accounts fall into this category, they will request your carbon intensity data, emission factors, or GHG inventories: not because of a legal obligation that falls on you directly, but because it is their obligation.
In other words, a carbon collection module in your ERP remains relevant if you supply companies subject to CSRD. The utility has changed in nature: from mandatory compliance, it becomes a competitive advantage and a commercial prerequisite.
Simplified ESRS: Fewer Datapoints, Less ERP Configuration
For companies that remain in scope, Omnibus I mandates the Commission to revise the ESRS (European Sustainability Reporting Standards) within six months of the directive entering into force. EFRAG, the technical body responsible for these standards, has been mandated to reduce the number of mandatory data points, clarify the distinction between mandatory and voluntary indicators, and strengthen the application of the materiality principle.
What this means on the ERP side: if you have already configured data collection flows based on current ESRS, an audit of your configurations will be necessary as soon as the revised ESRS are published. Some flows may be simplified or removed; others, deemed priorities, will need to maintain their current level of reliability and traceability.
ERP Vendors Are Adapting Their ESG Roadmaps
Major ERP vendors — SAP, Oracle, Workday, Sage, Microsoft — have all launched sustainability reporting modules or extensions over the past two years. None has announced a withdrawal or disengagement following Omnibus: the market of companies remaining in scope (roughly 5,000 in Europe) still represents a significant customer base. However, a shift in messaging is emerging: from regulatory obligation toward operational value (internal steering, voluntary reporting, green finance). Before making any decision on your ESG module, check directly with your vendor on their 2026–2027 roadmap and any pricing adjustments tied to the reduced regulatory scope.
For Companies Exiting CSRD Scope: Should You Really Stop Everything?
Scope 3 Pressure Remains: Your Listed Clients Need Your Data
This is the point many mid-sized companies underestimate when they breathe a sigh of relief. A company with 600 employees that exits CSRD scope will no longer be audited on its ESG data. But if it supplies a large listed company that remains in scope, that large company must report the carbon footprint of its entire supply chain (scope 3). It will therefore ask its suppliers to transmit their emissions data, social practices, or governance policies.
Platforms such as EcoVadis, CDP, or bespoke questionnaires are multiplying precisely to meet this need. Having an information system capable of producing this data in a traceable, repeatable, and auditable manner remains a genuine commercial differentiator, independent of any direct legal obligation.
Access to Green Finance and EU Taxonomy: Banks Continue to Require It
The European taxonomy of sustainable activities was not abolished by Omnibus. Banks and investors distributing green financial products (green bonds, green loans, ESG funds) remain subject to their own reporting obligations and maintain their eligibility criteria for borrowers. In practice, to access green financing or certain public calls for tenders, producing reliable ESG data remains a prerequisite that your ERP can facilitate.
Forward Planning: The Threshold Could Be Lowered in the Next Mandate
The Omnibus package is a political response to a specific economic context (European competitiveness, administrative burden perceived as excessive). A change in the European Parliament majority, international diplomatic pressure on sustainability standards, or simply the work of the Draghi competitiveness report could lead to further adjustments in coming years. Companies that maintain a minimal IT capability retain the ability to scale up quickly, whereas those who abandon everything will need to start from scratch.
Practical Recommendation: A “Lite” Module Rather Than a Full Suite
If you exit mandatory scope but remain exposed to scope 3 requests from your clients, the right posture is neither total abandonment nor maintaining an expensive full configuration. Aim for a minimal setup: collection of direct scope 1 and 2 emissions, a few key social indicators (headcount, accident rates, training hours), and a governance policy document. This addresses 80% of client questionnaires without requiring a dedicated sustainability reporting team.
For Companies Still Within CSRD Scope: What Changes in Their ERP?
Simplified ESRS: Audit Your Configurations Now
If you are among the roughly 5,000 companies remaining subject to CSRD, the good news is that the volume of data to collect will decrease. The bad news is that you do not yet know which data points will be removed: the revised ESRS will be published in H2 2026 at the earliest. The recommended posture is to precisely document your current collection flows, map them by ESRS standard, and schedule a configuration audit in your ERP as soon as the texts are available.
XBRL/iXBRL Format: ERP Connectors Remain Necessary
Submission of the sustainability report in XBRL/iXBRL format is maintained by Omnibus. The connectors between your ERP or ESG reporting tool and regulatory filing formats therefore remain a durable investment. This is not a budget line to cut.
Revised Timeline: Should You Delay an Ongoing Project or Press Ahead?
If you had a CSRD compliance project planned for 2025–2026, the revised calendar provides additional time. The recommendation is not to stop a project that is progressing well, but to use the delay to incorporate the simplified ESRS as soon as they are published, rather than configuring current standards only to revise them six months later.
CIO Action Plan: Adapting Your Post-Omnibus ERP ESG Strategy
The rational response to the Omnibus package comes down to four steps.
Step 1: Verify whether your company falls within the new thresholds. The calculation is done on consolidated data if you are part of a group. If your average headcount over the financial year exceeds 1,000 employees, you are potentially in scope — confirm with your legal counsel or statutory auditor based on the transposed national text.
Step 2: Audit ESG ERP investments already made. For each module or configuration deployed, identify its maintenance cost, the data it produces, and who uses it. Distinguish what responds to a regulatory obligation, what responds to a client demand (scope 3), and what no longer has a direct justification.
Step 3: Identify carbon data already useful outside regulation. List your five largest clients. Are they subject to CSRD? If so, they will request your carbon data. That alone justifies maintaining a minimal collection capability in your IT system.
Step 4: Decide with full information. Three postures are available: pausing the project (if you exit scope and have no client pressure), reorienting toward voluntary reporting and client requests, or accelerating toward compliance (if you remain in scope and can use the delay to better prepare). The fourth posture — total abandonment — is only defensible for companies with no major clients subject to CSRD.
Summary Table: Before and After Omnibus for Your ERP
| Obligation | Before Omnibus | After Omnibus | ERP Impact |
|---|---|---|---|
| Mandatory CSRD reporting | Companies > 250 employees (2nd wave) | Companies > 1,000 employees | Most mid-sized companies exit mandatory scope |
| 2nd wave CSRD deadline | FY 2025 (first publication 2026) | FY 2027 (first publication 2028) | 2-year extension for companies remaining in scope |
| ESRS standards | 12 standards, several hundred data points | Revised ESRS (publication end 2026) | ERP configuration audit to plan upon receipt of revised ESRS |
| XBRL filing format | Mandatory | Maintained | ERP-ESG reporting connectors still required |
| CSDDD 1st wave | July 2027, > 1,000 employees | July 2028, > 5,000 employees | ERP procurement/supplier modules: reduced scope but obligations maintained for those affected |
| Supplier scope 3 data | Growing client CSRD requests | Unchanged (client pressure maintained) | Minimal carbon collection remains justified for suppliers to large accounts |
For companies remaining in CSRD scope or continuing to face scope 3 requests from their clients, our complementary articles will help you go further: see our complete CSRD and ERP guide 2026 for a detailed view of sustainability reporting modules, and our guide for SMEs that exit mandatory scope but must respond to client questionnaires. For adjacent regulatory developments, the EU Carbon Border Adjustment Mechanism (CBAM) was not affected by Omnibus and applies to companies importing carbon-intensive goods.
